On October 31, 2025, CMS released its “CY 2026 Medicare Physician Fee Schedule Final Rule.”1 This Rule finalized a new payment model for skin substitute products applied to Medicare Part B beneficiaries during a covered application procedure in a non-facility setting and in the hospital outpatient department setting.
Many procedures have either a 10- or 90-day postoperative global period. Generally, any care provided within that period is included in the payment for the procedure. However, there are some exceptions. If a patient in a postoperative global period experiences a complication of the procedure for which they are in the global period and an evaluation and management (E&M) of that complication is performed, there is no modifier that allows for submission of that E&M. The only E&M modifier that can be used during a postoperative global period is the 24 Modifier which is only appropriate when an E&M service is performed for a problem unrelated to the procedure for which the patient is in the postoperative global period.
All seven Part B Medicare Administrative Contractors have finalized new, identical coverage policies that will govern the application of skin substitutes/cellular and tissue-based products applied to diabetic foot ulcers and venous leg ulcers for Medicare Part B beneficiaries. These policies only rigidly apply to diabetic foot ulcers and venous leg ulcers. These policies take effect January 1, 2026.
